Hurst v. Florida, 577 U.S. 92 (2016), was a United States Supreme Court case in which the Court, in an 8–1 ruling, applied the rule of Ring v. Arizona[1] to the Florida capital sentencing scheme, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty.
Under Florida law, the maximum sentence a capital felon may receive on the basis of a conviction alone is life imprisonment.
The court must still independently find and weigh the aggravating and mitigating circumstances before entering a sentence of life or death (§921.141(3)).
This procedure was adopted from 2013 when Governor Rick Scott signed the Timely Justice Act (HB 7101)[2] which overhauled the processes for capital punishment.
Florida's capital sentencing scheme, requiring that a judge instead of a jury to make the critical findings necessary to impose the death penalty, violated the Sixth Amendment in light of Ring v.
However, he agreed with striking Florida's scheme, referring back to Justice John Paul Stevens' concurring opinion in Spaziano, among others, that he believes that any imposition of the death penalty by a single government official instead of a jury violates the Eighth Amendment.
He also wrote that Arizona's sentencing scheme is very different from Florida's because under the former, a jury plays no role in the process.
[9] The court ruled that the law "cannot be applied to pending prosecutions" which means that until the Florida legislature acts, there is no procedure or law allowing a prosecutor to seek the death penalty; it leaves open, however, as in the aftermath of the Hurst ruling, the status of sentences passed under the now twice-struck-down provisions.
[11] The U.S. Supreme Court had received over 83 petitions from inmates on death row in Florida who believed that their cases had been decided incorrectly based on Hurst, in that the jury had unanimously recommended the death sentence while the judge had made the actual decision; these petitions followed after the Florida Supreme Court refused to re-hear these cases, on the basis that in all cases, there was beyond reasonable doubt that the juries would have decided on the death sentence.